State v. Jama

Summary

The Minnesota Supreme Court held that Minnesota's indecent-exposure statute, Minn. Stat. § 617.23, subd. 2, creates a general-intent crime rather than a specific-intent crime. Accordingly, the defendant was not entitled to a jury instruction on voluntary intoxication, and the court affirmed his conviction and the decision of the court of appeals.

Holdings

1. Indecent exposure under Minn. Stat. § 617.23, subd. 1(3), is a general-intent crime. The State must prove that the defendant volitionally, rather than accidentally, engaged in an openly lewd act, but it need not prove an additional specific intent to be lewd.
2. Jama was not entitled to a voluntary-intoxication instruction because voluntary intoxication is available only as a defense to specific-intent crimes, and indecent exposure is a general-intent crime.
3. The district court did not commit plain error by failing to instruct the jury on a specific-intent element because the indecent-exposure statute does not contain such an element.

Questions Presented

1. Whether Minn. Stat. § 617.23, subd. 1(3), as incorporated into the gross-misdemeanor offense in subdivision 2, requires the State to prove specific intent to be lewd or instead establishes a general-intent crime.
2. Whether Jama was entitled to a jury instruction on voluntary intoxication.
3. Whether the district court committed plain error by failing to instruct the jury on a specific-intent element.

Disposition

affirmed